Privacy policy
Last updated:
In short
- We use your data to teach you Finnish and nothing else. No advertising, no selling of data, no tracking across other sites.
- To generate conversations, feedback and speech, your messages are processed by AI and speech providers that work for us.
- You can see, correct, export and delete your data in the app at any time, and delete your whole account.
- Usage statistics are optional and off until you allow them.
1. Who is responsible
The controller of your personal data is Simulingo. SimuCoach is our service. For any privacy question or request, email [email protected].
2. What data we process
- Account: your email address, a securely hashed password (or, if you use Google sign-in, your Google account id and email), interface language, the date and version of the Terms of Use you accepted, and your privacy choices.
- Learner profile: the name you want to be called, native language, age group, goals, level, daily study time and preferred correction style. City, occupation and interests are optional.
- Learning data: your answers, exercises, mistakes, progress, review schedule, level checks and YKI practice answers.
- Conversations: role-play and assistant messages, including what you say by voice after it has been turned into text. In the assistant, personal identity codes, bank account numbers, email addresses and phone numbers are removed before saving.
- Learner memory: facts you share in conversations (for example your work or family), so the coach can personalise lessons. You can turn this off. Health and immigration matters are remembered only if you separately allow it.
- Photos: a photo you take in the assistant (for example of a letter) is processed to answer you and kept in memory for at most five minutes. It is never stored.
- Voice: your voice is sent to a speech-to-text provider to be turned into text. We do not store audio recordings.
- Child profiles in Kids Mode: a nickname, a ready-made avatar, an age group and game progress, added by a parent.
- Learning events: when a session starts and ends, and which exercises you do, so the adaptive engine can plan your next step.
- Optional usage statistics: which menus and buttons you use, only if you allow it. Never what you write or say.
- Technical data: IP address, time and address of each request in server logs, and error logs with your user id.
- Messages to us: error reports you send from the app, and emails.
3. Why we process it, and on what legal basis
- Providing the service you signed up for (account, lessons, exercises, conversations, feedback, speech, progress, learner memory, password reset email): performance of a contract, GDPR Article 6(1)(b).
- Remembering health or immigration matters, if you turn it on: your explicit consent, Article 9(2)(a).
- Optional usage statistics and sharing pseudonymised mistakes for quality evaluation: your consent, Article 6(1)(a). You can withdraw consent at any time in the app; this does not affect earlier processing.
- Security, preventing abuse and fixing errors (server logs, rate limits, error logs): our legitimate interest in keeping the service safe and working, Article 6(1)(f).
- Legal obligations, such as bookkeeping if paid plans are introduced: Article 6(1)(c).
We do not use your data for advertising and do not sell or rent it to anyone.
4. Artificial intelligence
SimuCoach uses AI language models to hold conversations, correct your Finnish, explain grammar and estimate your level. The voices you hear are AI-generated, not recordings of real people. AI can make mistakes, so the results are guidance only: SimuCoach makes no decisions that have legal or similarly significant effects on you (GDPR Article 22). Under our providers' business terms, the data we send them through their APIs is not used to train their models, and we ask providers not to retain it where they offer that option.
5. Who processes your data for us
We use the following service providers (processors). They may use the data only to provide their service to us, under data processing agreements.
- Hosting: our server hosting provider runs our servers and database.
- AI models: OpenAI (OpenAI Ireland Ltd / OpenAI, L.L.C., USA) or Anthropic (Anthropic, PBC, USA): your messages, relevant parts of your learner profile and memory, photos you send, and text to be read aloud.
- Speech-to-text: Deepgram, Inc. (USA), and OpenAI as a fallback: your voice, to turn it into text.
- Email: Brevo (Sendinblue SAS, France): your email address and the password reset message.
Google sign-in is optional. If you use it, Google tells us your account id and email address; Google's own privacy policy applies to your Google account. Your browser's speech recognition: if live speech recognition is not available on our side, the app may use the one built into your browser, which in Chrome and Edge sends your voice to Google or Microsoft.
6. Transfers outside the EU
Some providers are based in the United States. Transfers rely on the EU–US Data Privacy Framework for certified companies, and otherwise on the European Commission's Standard Contractual Clauses (GDPR Article 46) with additional safeguards. You can ask us for a copy of the safeguards at [email protected].
7. How long we keep data
- Account and learning data: as long as you have an account. When you delete your account, it is removed from our database at once, and from backups within 14 days.
- If an account has not been used for 24 months, we may delete it after telling you by email.
- Photos in the assistant: at most five minutes, in memory only. Audio: not stored.
- Server and error logs: a limited time, normally a few weeks at most.
- Password reset links expire after 60 minutes; a sign-in on a device lasts 7 days.
8. Your rights
You have the right to access your data, to have it corrected or deleted, to restrict or object to processing, to data portability and to withdraw any consent. Much of this you can do yourself in the app, in Me › What Pip remembers: view and delete memories, download all your data (export) and delete your account. For anything else, email [email protected]. We answer within one month.
You also have the right to lodge a complaint with the supervisory authority, the Data Protection Ombudsman in Finland (tietosuoja.fi), or with the authority in your own EU country.
9. Children and young people
You must be at least 13 years old to create an account. For users aged 13 to 17, the remembering of sensitive matters and quality sharing are turned off. Children under 13 use SimuCoach only through Kids Mode in a parent's account: the parent adds a nickname and an avatar, and the child's game progress is not used for profiling or statistics. The parent can delete a child profile at any time.
10. Security
Connections are encrypted (HTTPS), passwords are stored only as secure hashes, access to the database is restricted, and the app runs with strict browser security rules. No system is perfectly secure; if a breach could put you at risk, we will tell you and the authority as the law requires.
12. Changes
We update this policy when the service changes. The date at the top shows the current version; we tell you about important changes in the app.